Privacy Policy

Application Statement

Our Company has adopted, installed, and implements a Personal Information Management System (PIMS) according to the International Standard ISO 27701:2019, as an extension of the Information Security Management System (ISMS) according to the International Standard ISO 27001:2013.
The Policy of PIMS states:

the commitment of the administration,
responsibilities and roles,
constant commitment to improvement,
targeting issues.

In particular, our Company applies legal specializations according to the geographical and essential scope of its processing.

The implementation framework of the PIMS is determined by the General Data Protection Regulation but is not limited to it.

The implementation of the General Data Protection Regulation (GDPR) is a priority for f society.

f society accepts as personal data: Any information relating to an identified or identifiable natural person alive. For example, this information includes name, home address, ID number, Internet Protocol (IP) code, information about their health and insurance capacity, employment status, and more.

Special categories data, such as health, racial or ethnic origin, trade union activity, etc., receive special protection.

The rules apply when collecting, using, and storing personal data digitally or in hard copy through a structured filing system.

This policy is in line with the EU General Data Protection Regulation. (GDPR), and opinions/decisions issued by the Hellenic Data Protection Authority.

Terms and Definitions

Personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘Processing’ means any operation or set of operations which is performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
‘Restriction of processing’ means the marking of stored personal data to limit their processing in the future.
‘Filing system’ means any structured set of personal data which are accessible according to specific criteria, whether centralised, decentralised, or dispersed on a functional or geographical basis,
‘Controller’ means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the Controller or the specific criteria for its nomination may be provided for by Union or Member State law.
‘Processor’ means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller.
‘Recipient’ means a natural or legal person, public authority, agency, or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry by Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall comply with the applicable data protection rules according to the purposes of the processing.
‘Third party’ means a natural or legal person, public authority, agency or body other than the data subject, Controller, Processor, and persons who, under the direct authority of the Controller or Processor, are authorised to process personal data.
‘Consent’ of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
‘Personal data breach’ means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
‘Special categories data’ means personal data disclosing racial or ethnic origin, political views, religious or philosophical beliefs, or trade union affiliation, as well as the processing of genetic, biometric data for the data relating to health or data relating to the natural sexual life or sexual orientation of a person.

Categories of Personal Data Collected

In the context of its activities and its regular operation, f society may collect personal data of its customers or associates, its employees, its associates in general, and other natural persons with whom it trades within its operation.

Depending on the form and purpose of processing, f society may collect and process personal data, such as the following:

CATEGORIES OF DATA SUBJECTS	CATEGORIES OF DATA
f society’s clients	Customer data in the case of natural persons or legal representatives of legal persons, because “personal data” refers only to information relating to natural persons and does not fall into this category of data relating to legal persons such as companies and organizations. These may include: 1. Identity and demographics (e.g., name, patronymic, etc.) 2. Contact details (e.g., postal address, telephone, Email, etc.) 3. Professional Information 4. Trade Agreements 5. Bank Accounts 6. Account Balances 7. Image capture via video surveillance system 8. Other relevant information.
Suppliers/External Partners	The data of suppliers / external partners, in the case of natural persons or legal representatives of legal persons, because “personal data” refers only to information concerning natural persons and does not fall into this category of data concerning legal entities such as companies and organizations. These may include: 1. Identity and demographics (e.g., name, patronymic, etc.) 2. Insurance details (e.g., AMKA or ΑΥΠΑ and other information of the Social Security Institution Register if required) 3. Contact details (e.g., postal address, telephone, Email, etc.) 4. Professional Information 5. Bank Accounts 6. Account Balances 7. Image capture via video surveillance system 8. Other relevant information.
Employees (Active and Non-Active) / Candidate Employees	f society’s employee’s data, under any employment relationship as well as data of former and prospective employees, which are kept in official files or any other services for the purposes of operating their employment relationship with f society. These may include: 1. Identity and demographics (e.g., name, patronymic, etc.) 2. Contact details (e.g., postal address, telephone, Email, etc.) 3. Curriculum Vitae 4. Health data (eg medical certificates and opinions, blood donation data, etc.), 5. Financial data (eg bank accounts, etc.) 6. Marital status information (eg certificates and certificates, number and details of children, etc.) 7. Metadata and logs for the use of information systems 8. Image capture via video surveillance system 9. Other relevant information.
Data of other natural persons	The data of other natural persons who happen to visit the infrastructure of the company (facilities, website) or to cooperate with it or belong to collaborating bodies. These may include: 1. IP address 2. Anonymized traffic statistics 3. Contact email 4. Messages in the form of free text 5. Image capture via video surveillance system 6. Other relevant information

Table 1. The categories of Data and Data Subjects

Purposes and Legal Basis of Processing

f society may collect, and process personal data of customers and other individuals mentioned in the above paragraph who make use of its services and products. In principle, f society may collect and process personal data for the following purposes with the corresponding legal processing bases:

PURPOSE OF PROCESSING	LEGAL BASIS
The collection, processing, cross-checking and transmission of data of the Tax, Insurance and Labor Administration exclusively for the support and operation of its operating framework.	1. Processing is necessary for compliance with a legal obligation [Art. 6 §1 case. (c) GDPR] and/or 2. Processing is necessary for the performance of a contract to which the data subject obligation [Art. 6 §1 case. (b) GDPR] and/or 3. Processing is necessary for the purposes of the legitimate interests pursued by the Controller [Art. 6 §1 case. f) GDPR]
The collection and processing of the necessary data of employees and / or prospective employees and associates for the proper service of existing employment or cooperation relationships or the consideration of possible future cooperation.	1. Processing is necessary for compliance with a legal obligation [Art. 6 §1 case. (c) GDPR] and/or 2. Processing is necessary for the performance of a contract to which the data subject obligation [Art. 6 §1 case. (b) GDPR] and/or 3. Processing is necessary for the purposes of the legitimate interests pursued by the Controller [Art. 6 §1 case. (f) GDPR]
Concluding contracts in the context of providing or receiving products and services.	1. Processing is necessary for the performance of a contract to which the data subject obligation [Art. 6 §1 case. (b) GDPR] and/or 2. Processing is necessary for the purposes of the legitimate interests pursued by the Controller [Art. 6 §1 case. (f) GDPR]
The collection and processing of image data using closed circuit cameras (CCTV) for security reasons.	Processing is necessary for the purposes of the legitimate interests pursued by the Controller [Art. 6 §1 case. (f) GDPR]
For any other form of processing, f society seeks the written, free and prior informed consent of the subjects prior to processing, if required.

Table 2. The primary purposes and legal bases of processing

The reference to more than one legal processing base does not mean that f society is changing them (lawful basis swapping) by undermining the rights of the data subjects, but that there are cases where more than one legal processing base is applicable.

Finally, f society does not use as its primary processing base the consent of data subjects (whether it is simple data or special categories), according to the recommendations of the Working Group of No. 29 (now the European Data Protection Council). In exceptional cases, the subjects’ consent may be sought as a legal basis for processing (e.g., for the provision of additional services) when the processing cannot take place on a different legal basis. In these cases, the subjects are informed in advance and appropriately before giving their consent and retain full rights, including the withdrawal of consent.

Rights of Data Subjects

Data subjects have the right to:

Be informed about the processing of personal data.
Gain access to the personal data concerning them.
Request the correction of incorrect, inaccurate, or the completion of incomplete personal data.
Request the deletion of personal data when it is no longer necessary or if the processing is illegal.
Oppose to the processing of personal data for reasons related to their unique situation, subject to Article.21 par.6 of the GDPR.
Apply for a restriction on the processing of personal data in specific cases.
Submit a complaint to the Hellenic Data Protection Authority (1-3 Kifissias Ave., 11523 Ampelokipi, tel. 210.647.5600, www.dpa.gr) or to the supervisory authority of the EU Member State where they reside or work or to the supervisory authority of the place of the alleged violation.

Communication

The above rights, as well as any right regarding personal data, are exercised upon a written request submitted at the company’s premises (Kaniggos 14, 18534 Piraeus) or via electronic communication by sending an email to [email protected], which is also examined by the Data Protection Officer, as appointed by f society.

Processing principles

f society adheres to the principles governing the processing of personal data. According to article 5 of GDPR, personal data shall be:

Processed lawfully, fairly, and transparently concerning the data subject (lawfulness, fairness, and transparency).
Collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes shall, under Article 89(1), not be considered to be incompatible with the initial purposes (‘purpose limitation’).
Adequate, relevant, and limited to what is necessary for relation to the purposes for which they are processed (‘data minimization’).
Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that inaccurate personal data regarding the purposes for which they are processed are erased or rectified without delay (accuracy).
Kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for more extended periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes under Article 89(1) subject to the implementation of the appropriate technical and organizational measures required by this Regulation to safeguard the rights and freedoms of the data subject (storage limitation).
Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures (integrity and confidentiality).

Records of Processing Activities

f society keeps records of processing activities for the processes for which it acts as Controller and as Processor.

In the first case, the file contains all the following information:

the name and contact details of the Controller and, where applicable, of the joint Controller, of the Controller’s representative, and of the data protection officer,
the purposes of the processing,
a description of the categories of data subjects and the categories of personal data,
the categories of recipients to whom personal data are to be disclosed or disclosed, including recipients in third countries or international organizations,
where applicable, transfers of personal data to a third country or international organization, including the designation of that third country or international organization and, in the case of transfers referred to in the second subparagraph of Article 49 (1), documentation of appropriate guarantees,
where possible, the deadlines for deleting the various categories of data,
where possible, a general description of the technical and organizational security measures referred to in Article 32 (1).

The second case includes the following:

Name and contact details of the Controller.
Name and contact details of the representative of the Controller (where applicable).
Name and contact details of the contracting Processor (where applicable).
Name and contact details of the representative of the Processor (where applicable).
Processing categories.
Where applicable, transfers of personal data to a third country or international organization, including the identification of that third country or international organization and, in the case of transfers referred to in the second subparagraph of Article 49 (1), documentation of appropriate guarantees.
General description of organizational and technical safety measures (where possible).

The above records comply with the General Data Protection Regulation requirements, the opinions of the Hellenic Data Protection Authority, and the requirements of the International Standard ISO 27701: 2019.

Personal Data Security

Taking into account the nature, scope, context and purposes of the processing, as well as the risks of different probability and severity of the rights and freedoms of individuals, f society implements appropriate technical and organizational measures to ensure and ensure can prove that the processing is carried out under the GDPR, adopting and applying a holistic policy of personal data security

In assessing the appropriate level of security, account shall be taken in particular of the risks arising from processing, including accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to personal data transmitted, stored, or otherwise processed.

To prevent the occurrence of a personal data breach, f society has adopted and implements an Information Security Management System following the requirements of International Standard ISO 27001: 2013, International Standard 27701: 2019, and a specific policy for the management of personal data breach cases.

Staff Awareness

f society accepts that personal data protection presupposes the awareness of its human resources regarding the protection of personal data. In this regard, it agrees with adopting and applying the principle of proper education guidance using Fair Information Practices (FIP), which condenses a set of standards governing the collection and use of personal data and addressing privacy issues and accuracy.

f society seeks to raise awareness of fundamental concepts of personal data protection on its human resources. Their training should focus on the Principles of Fair Information Practices (FIPP), the “backbone” of most privacy laws.

Particularly:

FIPP on Data Protection – principles on the legality and limitation of collecting personal data.
FIPP on the Processing and Use of Data – principles regarding the degree of sensitivity of the data, the limited access to it, the observance of confidentiality, the finiteness of the processing, the specification of the purpose of the processing, and its safe conduct.
FIPP on Individual Data Entity Participation – principles regarding data subjects’ rights, such as the right of access, the right of correction in case of inaccurate information, the right of timely notification of data subjects, and the securing of their legal consent.
FIPP on Data Transfer – principles on transferring and disclosing personal data to third parties (legal or natural).
FIPP on f society Accountability, principles on f society privacy policy and the role of the Data Protection Officer (DPO) in data security.

Amendment

This policy may need to be amended in the future regarding the processing of personal data. If the modification of these terms is of such an extent that the above data processing terms do not cover it, f society will publish the new version of the policy.

Date of Issue: 01 July 2021